Multi-Sector Air Pollutants Regulation, Part 2: Stationary Spark-Ignition Engines

The Government of Canada published the Multi-Sector Air Pollutants Regulation (‘MSAPR’) on June 17, 2016. The regulation was made pursuant to the Canadian Environmental Protection Act, 1999 and is administered by Environment and Climate Change Canada (ECCC}. The regulation applies in all provinces.

The intent of the regulation is to reduce NOx emissions from stationary spark-ignition engines by the application of NOx emission limits and requiring regular emissions testing and reporting.

MSAPR Part 2 applies to stationary spark-ignition engines that combust gaseous fuels; both:

“Pre-existing” engines, defined as those engines manufactured and owned and operated prior to September 15, 2016, and
“Modern” engines, defined as engines manufactured on or after September 15, 2016.

MSAPR Part 2 applies to “regular-use” pre-existing engines located at:

oil and gas facilities used to produce, transport or process hydrocarbons, including gas storage and water injection facilities.

MSAPR Part 2 applies to “regular-use” and “low-use” modern engines located at:

oil and gas facilities used to produce, transport or process hydrocarbons, including gas storage and water injection facilities
oil sands facilities, including mining and thermal production operations and upgraders
regulated facilities in other industrial sectors.

“Regular-use” engine is defined as an engine operated for at least one hour during a year, and not elected as “low-use”.

“Low-use” engine is an engine operated less than 1314 hours in consecutive 3-year periods, excluding emergency use (e.g. emergency generator, or pump in the event of a fire or flood).

MSAPR Part 2 requirements include:

Pre-Existing engines

Pre-existing engines >250 kW must be registered with ECCC by January 1, 2019.
There are three compliance options to meet NOx emissions intensity limits:

Engines not in a Group

As of January 1, 2021, all pre-existing regular-use engines >250 kW must meet a NOx limit of 4 g/kWh output or 210 ppmvd at 15% oxygen.

2.Engines in a Group – Per Engine Approach

This option provides a phase-in of when NOx emission limits apply to engines, and an opportunity to defer some costs for emissions controls and emissions testing until 2026.
Engines must be designated to a group before January 1, 2021.
Between 2021 and 2025 (inclusive) – a subset of pre-existing regular-use engines with at least 50% of the total rated brake power of the group must meet a NOx limit of 4 g/kWh output or 210 ppmvd at 15% oxygen.
As of January 1, 2026, all of the pre-existing regular-use engines in the group must meet a NOx limit of 4 g/kWh output or 210 ppmvd at 15% oxygen.

3.Engines in a Group – Yearly Average Approach

This option provides a phase-in of NOx emission limits, and an opportunity to reduce and/or defer some costs for emissions controls and emissions testing to 2026 and beyond.
Engines must be designated to a group, and ECCC notified by October 31, 2020, if the yearly average limit option is selected.
Between 2021 and 2026 (inclusive) – pre-existing regular-use engines must meet a yearly average NOx limit of 8 g/kWh output or 421 ppmvd at 15% oxygen.
Effective January 1, 2026, the yearly average NOx limit decreases to 4 g/kWh output or 210 ppmvd at 15% oxygen.
The yearly average NOx limit is calculated using the rated brake power, operating hours, and NOx emission values of all engines; this option requires that engine operating hours are recorded.
This option provides for replacement of a pre-existing engine with a modern engine, an electric motor, or a low-NOx turbine, to use in the yearly average calculations.
Installation of sampling test ports in engine exhaust piping.
Emissions testing of pre-existing regular-use engines: ‘performance tests’ and ‘emissions checks’
- within 12 months of when emissions limits apply to individual Pre-existing engines (initial deadline as early as December 31, 2021, or can be deferred until 2026)
- initial test for engines > 250 kW, subsequent tests for engines > 375 kW
- less frequently for lean-burn engines, more frequently for rich-burn engines
Compliance Reports: due by July 1 annually, for preceding calendar year, starting in 2022.

Modern engines

Modern engines >75 kW must be registered with ECCC annually by July 1 for the preceding year, starting in 2017.
NOx emissions intensity limits for modern engines, applicable upon first operation of engine:
- regular-use engines >75 kW: 160 ppmvd15% or 2.7 g/kWh
- low-use engines > 100 kW: 160 ppmvd15%
Installation of sampling test ports in engine exhaust piping.
Emissions testing: ‘performance tests’ and ‘emissions checks’
- within 12 months of first operation
- less frequently for lean-burn engines, more frequently for rich-burn engines
Compliance Reports: due by July 1 annually, for preceding calendar year, starting in 2017 (or later year, depending on when a modern engine is first operated).

MSAPR Part 2 also includes requirements to follow manufacturer’s recommendations for maintenance, and for various record-keeping – for both pre-existing and modern engines.

How can we help?
Process Ecology can help you comply with MSAPR.

Compliance Awareness Training
Process Ecology can provide awareness training to your company personnel who will be involved with planning and implementing the MSAPR requirements e.g. operations, maintenance, facility engineers, asset managers.

Engine Registry
Process Ecology can assist you to compile and submit initial engine registrations and annual registry updates to ECCC.

Compliance Planning and Cost Management
It is critical to commence compliance planning for pre-existing engines during 2019 and 2020.

MSAPR will impose new costs on operators of pre-existing engines, in order to meet requirements for emissions controls, emissions testing, record-keeping and reporting. Compliance costs for emissions controls and emissions testing can be minimized and deferred with good planning prior to 2021. A second round of compliance planning will be required prior to 2026.

Process Ecology can assess your engine inventory and make recommendations regarding:

engine designations
selecting compliance option for pre-existing engines
calculating yearly average emissions intensities
optimizing capital investments in engine emissions controls (e.g. air-fuel ratio controllers and catalyst systems for rich-burn engines)
optimizing emissions testing obligations
estimating costs for pre-existing engines – emissions controls and emissions testing
record keeping.

Annual Compliance Reports
Process Ecology can help you compile and submit annual compliance reports to ECCC.